Custom or off-the-shelf target date strategies?

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1 NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE Custom or off-the-shelf target date strategies? The choice requires careful consideration July 2015 AUTHOR Daniel Oldroyd, CFA, CAIA Head of Target Date Strategies Multi-Asset Solutions IN BRIEF Choosing between custom or off-the-shelf target date strategies requires extensive analysis. Plan sponsors and financial advisors need to balance the benefits that custom strategies might offer with the required expertise, time and costs, which can be significant. Custom target date strategies can be precisely designed to meet specific plan requirements. These strategies can take into account employee demographics and particular plan design features (for example, a prohibition against plan loans or pre-retirement withdrawals). In a custom strategy, a plan sponsor can consolidate investment managers from defined benefit (DB) plans to potentially achieve economies of scale and realize savings on overall fees. But a substantial asset base (greater than $500 million) may be needed to secure those savings. Smaller plans will likely be better served by an off-the-shelf target date strategy. Effective communications are critical when implementing a custom strategy. While participants in an off-the-shelf target date strategy can access relevant information about their strategy s funds on fund company websites, participants in a custom strategy may have only one source of information about their retirement funds: the communications they receive from their plan sponsor.

2 AS TARGET DATE STRATEGIES CONTINUE TO become more prevalent in defined contribution (DC) plans, more plan sponsors are contemplating custom offerings that can be tailor-made to meet the specific goals and objectives of individual plan sponsors. In February 2013, the U.S. Department of Labor (DOL) provided tips on the target date selection process, which included guidance on the considerations in selecting custom target date strategies. When does it make sense to choose a custom target date strategy instead of an off-the-shelf one? It s a complicated question. For the right plan sponsor, for the right reasons, a custom target date strategy can be the better option. But the choice needs to be carefully examined. Any plan sponsor or advisor weighing the pros and cons should know that custom target date strategies require substantial resources, investment expertise and organizational capability. This paper presents a framework for thinking about this important decision. In the following pages, we explore the considerations a plan sponsor should examine, which include costs and benefits, risks and rewards of custom target date strategies. Which plan sponsor might be well-suited to adopting a custom strategy? Who may be better served by off-the-shelf? What potential advantages and pitfalls should be evaluated before choosing a custom target date strategy? DEFINING TERMS The word custom is loosely used to describe a fairly wide range of offerings. Here s how we distinguish between custom and off-the-shelf target date strategies. In an off-the-shelf target date strategy, which is the traditional approach, a portfolio management team analyzes a variety of criteria in order to identify a goal. They then establish an appropriate asset allocation strategy to meet that goal. The change in asset allocation as the fund gets closer to its target date is known as the glide path. Within the glide path, the team selects a mix of asset classes and then determines how best to gain exposure to the assets within the mix, whether through active or passive management or some combination of the two. The team may seek to deploy tactical asset allocation, making measured, opportunistic shifts in asset weightings while remaining close to the glide path. With a few exceptions, off-the-shelf target date strategies are also known as proprietary strategies because they include the proprietary funds of the target date fund provider. Custom strategies usually contain non-proprietary funds, but may also include funds managed by the glide path manager. As more plan sponsors choose target date strategies as their plan s qualified default investment alternative (QDIA), these investment vehicles hold a growing share of DC plan assets. According to Cerulli Associates Retirement Markets 2014, target date funds accounted for 13% of DC plan assets and 38% of contributions in Cerulli projects that those percentages will rise to 34% and 88%, respectively, by Yet even as the DOL guidance encouraged plan sponsors to evaluate whether custom target date strategies make sense, Cerulli finds that less than 10% of all target date assets are actually in custom offerings. The three components used in constructing any target date strategy include: glide path/asset allocation manager selection implementation (including cash flow management and tactical asset allocation) In an off-the-shelf target date strategy, an asset manager oversees all three components. But, in a custom strategy, the components can be disaggregated. When this occurs, there must be complete clarity about the roles and responsibilities of the plan sponsor, the glide path manager, the asset manager and the party responsible for implementation, which is usually the recordkeeper or the custodian of the plan (see The benefits and challenges of custom target date strategies, next page). HOW DO CUSTOM TARGET DATE STRATEGIES WORK? Although there are many varieties of custom target date strategies, they generally fall into one of two categories: complete customization or the recordkeeping platform model. 2 RETIREMENT INSIGHTS

3 For the fully customized approach, a plan sponsor hires a glide path manager, usually an investment firm, to design and manage a plan s glide path. The plan sponsor either selects the underlying managers itself or outsources the decision to a consultant. Management of cash flows and portfolio rebalancing are handled by the recordkeeper or custodian. Participant communications are provided by either the plan sponsor, glide path manager or recordkeeper. In the platform model, a plan sponsor often with help from a consultant or financial advisor selects a custom target date strategy on a recordkeeping platform. Typically, the recordkeeper will offer several glide paths for the plan sponsor to choose from. In general, the recordkeeper works with an investment firm to create the custom glide path options (ranging from conservative to aggressive in investment approach, thereby creating different glide path flavors ) and provide a lineup of underlying managers. (That manager roster may be limited to funds within the core menu offering and therefore may not have access to extended asset classes such as high yield fixed income, emerging market equity or alternatives such as real estate or hedge funds.) Whenever a plan sponsor adopts a target date strategy, whether it is off-the-shelf or custom, it constitutes a fiduciary act. The plan sponsor s fiduciary obligation is in no way diminished, whether the choice is custom or off-the-shelf. A plan sponsor must always act prudently in the selection and monitoring of plan asset investment options. When evaluating and selecting any target date portfolio, fiduciaries should: define plan objectives assess participant behavior and risk tolerance consider workforce demographics, compensation levels, contribution rates and turnover patterns The DOL discusses these various considerations in its February 2013 publication, Target Date Retirement Funds Tips for ERISA Plan Fiduciaries. For further discussion of fiduciary obligations when selecting a custom strategy, see Appendix A (page 8). WHY CONSIDER CUSTOM? To establish the goals of any DC plan, plan sponsors need an intimate knowledge of their participant population. Often, plan sponsors lean toward a custom target date strategy over an off-the-shelf offering because they think a tailor-made approach would better address specific characteristics of their plan, such as the demographic profile of their participants. But even after they identify those specific participant profiles, plan sponsors may be able to find an off-the-shelf target date strategy that can accommodate them. Many existing target date strategies take into account the differences in participant THE BENEFITS AND CHALLENGES OF CUSTOM TARGET DATE STRATEGIES BENEFITS Tailor-made to meet specific requirements of plan sponsors Plan sponsor control of glide path design and underlying manager selection Can consolidate managers from DB plans to potentially achieve economies of scale Potential fee savings Can assemble best-in-class manager roster Can incorporate extended asset classes (such as real estate and hedge funds) CHALLENGES Substantial target date resources and investment expertise are required Substantial asset base (greater than $500 million) may be needed to achieve economies of scale Complex administration, demanding reporting requirements Need strong, consistent oversight of manager selection Recordkeeping platforms may not be able to accommodate Tactical asset allocation may be difficult J.P. MORGAN ASSET MANAGEMENT 3

4 profiles across industries and sectors. J.P. Morgan s Target Date Compass SM, a tool to compare different target date approaches, identifies 58 distinct offerings in the U.S. marketplace today. 1 Such a breadth of offerings suggests that there is a strong likelihood that a plan sponsor can find an off-the-shelf option that will work well for its participants. Some plan sponsors, however, do have unique participant demographics and face particular plan design issues that could make it impossible to find a suitable off-the-shelf target date strategy. For example, an organization that requires participants to retire at age 60 will necessitate specific plan parameters that may be best incorporated in a custom target date strategy. So too would a DC plan that prohibits plan loans or pre-retirement withdrawals. Another group of plan sponsors may be drawn to custom target date strategies because they would like their DC plan investments to mirror their DB plan as much as possible in order to achieve potential economies of scale. For questions to ask when considering whether a custom target date strategy is right for your plan, see Appendix B (page 9). AN EYE ON ASSET ALLOCATION A plan sponsor may be pleased with an off-the-shelf target date strategy but may still want some control over the asset allocation that shapes a glide path. For example, a company 1 J.P. Morgan Asset Management, based on information provided by Morningstar, framed within the Target Date Compass SM ; as of March 31, may prefer to include, or exclude, real estate in its menu of available asset classes. The use of derivatives may be allowed, or prohibited. But whatever specific asset classes are chosen, plan sponsors should not lose sight of a critical element of asset allocation: asset classes should be selected in a risk-controlled fashion. A plan sponsor may consider a custom target date strategy because it offers an asset class or strategy that is otherwise unavailable in an off-the-shelf strategy or core menu. For example, a company may have an allocation to hedge funds or deploy a risk parity strategy in its DB plan, strategies that are not often found in off-the-shelf target date offerings. Given the uncertainty of the current market environment, plan sponsors are increasingly evaluating asset classes and approaches outside the traditional off-the-shelf framework. Alternative assets, which we define as direct real estate, commodities, hedge funds, private equity/venture capital and infrastructure, are often a draw for plan sponsors considering custom target date strategies. This is partly because, in a custom strategy, plan participants do not determine the size of the alternative asset allocation, whereas in a DC plan account, they do. As a result, the allocation to alternatives can be appropriately weighted in a custom structure. In an off-the-shelf strategy, on the other hand, a plan sponsor would have to contemplate the possibility that participants would make improperly sized allocations to an alternative asset class (see Weighing the role of alternative assets, below). WEIGHING THE ROLE OF ALTERNATIVE ASSETS As plan sponsors carefully evaluate the role played by alternative assets in custom target date strategies, they should consider these questions: Can the asset class be bought and sold easily? Can it potentially affect the liquidity of the entire portfolio? How transparent is the value it adds to the portfolio? What are its risk/return and correlation characteristics? Plan sponsors pondering custom target date strategies with an eye toward alternative assets are well advised to select a manager with experience and a strong track record in managing alternative assets. 4 RETIREMENT INSIGHTS

5 MANAGER MIX Some plan sponsors opt for a custom target date strategy because they hope to use it to assemble a best-in-class manager roster. Though plan sponsors should always aspire to achieve individual manager excellence, they should never lose sight of a critical goal: creating a proper mix of asset class exposures for their participants. Too many managers of target date strategies select underlying managers (even excellent underlying managers) who do not complement one another. The most capable target date managers have a deft touch in assembling a mix of managers that collectively enhance the overall portfolio. In this way, the whole may be greater than the sum of its parts. Other plan sponsors may like the manager roster of an off-the-shelf target date strategy except for a single name for socially responsible reasons, for example and conclude that they will be better served by a custom solution simply because of the one problematic manager. This seldom happens, but a custom target date strategy may not be an optimal approach to solve this issue. Just as a plan sponsor allows an equity fund manager to decide, say, whether to buy Apple stock, so too will a plan sponsor give an off-the-shelf target date strategy manager the flexibility to assemble an appropriate investment manager roster. In this regard, plan sponsors should understand why the underlying managers in their target date strategy have been chosen, and then carefully monitor their performance. The plan sponsor should also confirm that a target date manager follows a process to avoid getting stuck with a poor-performing investment manager. Even when such a process is in place, performance issues can mandate a manager change. When that happens, timing considerations may come into play. While off-the-shelf target date managers can have a seamless process in the selection and monitoring of underlying managers, as well as the ability to replace an investment manager fairly quickly, a custom strategy often requires investment committee approval for manager changes. A committee may require that a manager be placed on watch before it is fired. Once a final decision is made, there may be a further delay before the manager change is effected. A recordkeeping platform may take a few weeks to remove an underlying manager from its lineup. Are these issues insurmountable? Certainly not. But they do highlight the fact that custom target date strategies demand strong and consistent oversight of manager selection. FOCUS ON FEES Some plan sponsors assume that custom target date strategies offer lower fees than institutionally priced mutual funds or collective trusts. In fact, that is often not the case. Plan sponsors should bear in mind that they will be making separate payments to the glide path manager for glide path design, to the custodian and to the recordkeeper for implementation. Custom target date strategies may be less expensive than their off-the-shelf counterparts when they have a preponderance of passive managers. We would note that if a plan sponsor is focused on fees to the exclusion of all other factors, then an all-passive approach may make the most sense. Some large plan sponsors believe they will reduce their overall fees by allocating more assets to managers they have already placed in their DB or DC plan lineups. Clearly, there may be economies of scale to be found when the same managers are handling investments for DB and DC assets. But a plan sponsor needs a substantial asset base more than $500 million in target date assets, we d estimate to gain those cost savings. Also, plan sponsors that want to consider using the same managers for DB and DC plan assets in order to reduce their investment management fees should examine the potential conflicts and legal issues of that approach (see Custom target date strategies and DB plans, next page). OPERATIONAL STRUCTURE The operational structure of all target date strategies is complex, but it is especially intricate for custom strategies. As a result, it is critical that a plan sponsor choose the best possible partners to help manage that complexity. Moving cash from plan participants to custodians and recordkeepers and then to an investment manager is an elaborate undertaking. Every step along the way, rules and processes must be put in place, and strictly observed. Well-defined responsibilities and flawless project management are essential. J.P. MORGAN ASSET MANAGEMENT 5

6 In handling cash flows, managers of off-the-shelf target date strategies may be better able to eliminate unnecessary transactions than their custom counterparts. Say an investment decision is made to tactically overweight U.S. equities by one percent, and the off-the-shelf target date manager knows that in one week, a week s worth of cash flow will provide the necessary funds to gain the added one-percent exposure to U.S. equities. As a result, there would be no need to sell any securities to immediately gain the added one-percent exposure. But a custom target date manager may not have that flexibility. Recordkeeping platforms often follow rigid rules about how daily cash flow is invested and how rebalancing is conducted. (Is the portfolio rebalanced monthly? Quarterly? And how long does the process take?) These rules may sharply restrict the ability of the custom strategy manager to tactically manage cash flows. Indeed, although tactical asset allocation can add real value, it can be very difficult to implement in a custom target date strategy context. Imagine that the target date manager identifies a very short-term opportunity to, say, add to high yield bond exposure. On a recordkeeping platform for custom strategies, making that shift may be something less than a seamless process. PARTICIPANT COMMUNICATIONS Most plan sponsors would acknowledge that participant communications are an important component of their retirement programs. Without robust communications, no plan sponsor can succeed in delivering the best possible retirement outcomes for employees. But effective communications are absolutely critical when implementing a custom strategy. While participants in an off-the-shelf target date strategy can access relevant information about their strategy s funds on fund company websites, participants in a custom strategy may have only one source of information about their retirement funds: the communications they receive from their plan sponsor. As they do in all their target date strategies, plan sponsors should strive to ensure that participants have a thorough understanding of the strategy s inherent risk, glide path design, portfolio management philosophy and underlying investment components. CUSTOM TARGET DATE STRATEGIES AND DB PLANS Plan sponsors that also manage DB plans (those that are open or, more commonly, closed to new participants) should consider how custom target date strategies might complement their DB offering. Custom strategies offer plan sponsors an opportunity to consolidate underlying managers that are the same in both DB and DC plans. Whereas many off-the-shelf target date strategy managers use proprietary funds in their manager lineups, custom managers include non-proprietary funds. As a result, they can include firms that manage a firm s DB plan assets, which have already been pre-selected and vetted from a due diligence perspective. Using the same managers across custom target date strategies, DB and DC plans can also provide the potential for efficiencies and economies of scale in investment management fees. But these economies of scale and fee savings may also present certain conflicts of interest if the goal of fee reduction distorts asset allocation decisions. For example, if a plan sponsor knows that increased commitments to, say, the XYZ large cap growth fund will result in lower fees, that plan sponsor may have an incentive to include more equities at various points along the glide path (and thus get the fee break on the XYZ fund). By committing to the XYZ fund, the plan sponsor might miss an opportunity to choose a superior large cap growth manager. Can a plan sponsor that also manages a DB plan adopt a more aggressive glide path in a custom target date strategy because employees can take more market risk when they can rely on a guaranteed stream of income in retirement? This is a complicated question, beyond the scope of this paper. Each plan sponsor will need to address the issue within the context of its own specific goals and objectives. Plan sponsors contemplating this approach should bear in mind that a more aggressive approach may lead to a wider range of participant outcomes. We would note, too, that a more aggressive glide path can also be realized in a more aggressive off-the-shelf target date strategy. As they examine the use of custom target date strategies, plan sponsors that also manage pension plans should take a holistic approach, considering both the potential synergies and conflicts that custom target date strategies might present. 6 RETIREMENT INSIGHTS

7 In a custom context, a variety of nuances come into play. For example, participants must understand that the risk of a strategy remains in place, despite the fact that the custom strategy is constructed, managed and monitored by investment professionals. Participants must also be aware of the fact that custom strategies will include an added layer of investment management fees. Certain circumstances present specific demands on plan sponsors that offer custom strategies. If a custom strategy includes managers or asset classes that are not included in the plan s core fund lineup, the plan sponsor is obliged to communicate that fact to all participants. CHOOSING A CUSTOM TARGET DATE STRATEGY MANAGER CONCLUSION In all target date strategies, both custom and off-the-shelf, participants can access powerful asset class diversification that becomes progressively more conservative as retirement approaches. Like many in the industry, we expect that target date strategies will become increasingly popular for many years to come. But for plan sponsors and advisors, weighing the pros and cons of a custom vs. an off-the-shelf target date strategy can never be a simple exercise. Many factors must be taken into account, and plan sponsors and advisors need to be careful and thoughtful in their analysis. Off-the-shelf strategies can be a powerful tool to help participants reach their retirement goals. For the appropriate plan sponsor, properly structured custom strategies can be very effective as well. Once a plan sponsor decides that a custom target date strategy is the best choice for its plan participants, what is the best approach to choosing a custom manager? First, the plan sponsor should ask a lot of questions. For a list of potential questions to ask of a custom target date strategy provider, see Appendix C (page 10). A plan sponsor should ensure that its custom target date strategy manager boasts a long tenure and a strong track record in managing off-the-shelf funds, along with a background in the custom space. Experience in managing extended asset classes can be especially useful. Because custom management involves complex project management and organizational skills, a plan sponsor should know which recordkeepers or custodians the custom manager has worked with in the past. Otherwise, the plan sponsor will have no way of knowing if the custom target date strategy manager is up to the task at hand. J.P. MORGAN ASSET MANAGEMENT 7

8 APPENDIX A Legal considerations in selecting a custom target date strategy By Bruce Ashton, Partner, Drinker Biddle & Reath Employee Benefits & Executive Compensation Practice Group Plan fiduciaries must engage in a prudent process in selecting any target date strategy, whether off-the-shelf or custom. That process will involve gathering and assessing relevant information and making informed and reasoned decisions. Although the considerations for selecting off-the-shelf and custom strategies are similar, a prudent fiduciary will need to evaluate additional factors in selecting a custom strategy: Need for a custom strategy What are the special plan features, employer benefits or demographic factors that warrant the establishment of a custom strategy? Asset classes Fiduciaries determine the asset classes to be represented in the glide path and consider whether any asset classes unavailable in off-the-shelf products should be included in the custom strategy. This requires additional due diligence and expertise on the part of a fiduciary. Underlying strategies Fiduciaries are responsible for selecting the underlying assets and assuring their prudence. This duty can be shifted to a 3(38) manager (a bank, insurer or registered investment advisor that is given discretion to make investment decisions for a plan or for a portion of plan assets). But if that duty is shifted, fiduciaries will need to prudently select and monitor the 3(38) manager, taking into consideration both its experience and competence as an investment professional as well as its background in managing target date strategies. Glide path Fiduciaries are responsible for determining the glide path. Considerations here are essentially the same as they are for an off-the-shelf product. Costs Fiduciaries must select and monitor multiple service providers, including the investment manager, the recordkeeper and the custodian, while taking into account the fees and compensation of each one. Service provider competence Fiduciaries must insure that each service provider has the credentials, experience and infrastructure to manage the strategies in accordance with the structure and standards set by the plan fiduciaries. 8 RETIREMENT INSIGHTS

9 APPENDIX B Is a custom target date strategy right for your plan? Plan sponsors must weigh the potential benefits of a custom target date strategy against the costs and administrative tasks involved in creating one. Plan sponsors may use the checklist below as a quick tool for assessing whether a custom target strategy might be right for their plan. The checklist is not, however, a substitute for a comprehensive due diligence process. Remember, a custom strategy may not be right for every plan. If you answer No to many of these questions, or are unsure, you may be better served with an off-the-shelf option. BASICS YES NO Are there unique aspects of your plan (e.g., employee demographics and/or plan design features) that you have determined cannot be addressed in an off-the-shelf target date strategy? Are there other components of your benefits package (e.g., a DB plan) that would merit a custom target date strategy? Do you have a sufficient asset base (over $500 million in target date assets) to achieve potential economies of scale? Are plan fiduciaries educated with respect to their duties and obligations when selecting a custom target date strategy vs. an off-the-shelf product? INVESTMENT-RELATED Do you believe that a glide path should include certain asset classes that are not available in an off-the-shelf product, such as: Those available in your DB plan? OR Those not traditionally found in your DC core menu? Do you believe there is opportunity to compile a best-in-class roster of underlying managers whose strategies are additive to the overall target date portfolio, and have you determined that this roster of underlying managers is not available in an off-the-shelf product? Do you have a process to periodically monitor underlying investments that you would select for a custom target date strategy and to prudently evaluate whether to keep or replace them, as well as to maintain adequate documentation of their review? Are you looking to incorporate tactical asset allocation into the management of the target date strategy, and if so: Have you determined that you cannot obtain this in an off-the-shelf product; and Is your custom provider able to provide tactical asset allocation and do so efficiently? ADMINISTRATION AND IMPLEMENTATION Are you prepared to perform individual due diligence on all of the component parts of a custom target date strategy, which include the glide path design, custody, investment management and consultant selection? Are you comfortable paying a la carte fees for glide path design, custody, investment management, consultant selection and other service providers? Are you or your service provider prepared to provide participant communications on a customized target date strategy (e.g., fact sheets, brochures, website)? J.P. MORGAN ASSET MANAGEMENT 9

10 APPENDIX C Questions to ask of a custom target date strategy provider SERVICES OPERATIONS PROJECT MANAGEMENT Describe your custom target date strategy services. Provide a list of recordkeepers with whom you work. Indicate whether you have established data feeds with each. Provide a list of trustees/custodians with whom you work. Is the plan sponsor required to provide official direction? Describe the day-to-day communications and operational processes used to manage the glide path when daily cash flows are determined, including: Controls Reconciliations Automated feeds Error handling Cash flow management Describe the typical account set-up process. What is the expected time frame for the account set-up process? Who would the implementation project manager be, if applicable? What involvement is required of the client or of the client s vendors during implementation? What are the principal events that must coincide for a successful implementation? Source: Selecting Target Date Funds: The RFP Process, Fred Reish and Bruce Ashton, Drinker Biddle & Reath LLP, August RETIREMENT INSIGHTS

11 TARGET DATE FUNDS. Target date funds are funds with the target date being the approximate date when investors plan to start withdrawing their money. Generally, the asset allocation of each fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The principal value of the fund(s) is not guaranteed at any time, including at the target date. Contact JPMorgan Distribution Services at for a fund prospectus. You can also visit us at Investors should carefully consider the investment objectives and risks as well as charges and expenses of the mutual fund before investing. The prospectus contains this and other information about the mutual fund. Read the prospectus carefully before investing. Opinions and estimates offered constitute our judgment and are subject to change without notice, as are statements of financial market trends, which are based on current market conditions. We believe the information provided here is reliable, but do not warrant its accuracy or completeness. This material is not intended as an offer or solicitation for the purchase or sale of any financial instrument. The views and strategies described may not be suitable for all investors. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, accounting, legal or tax advice. References to future returns are not promises or even estimates of actual returns a client portfolio may achieve. Any forecasts contained herein are for illustrative purposes only and are not to be relied upon as advice or interpreted as a recommendation. JPMorgan Funds are distributed by JPMorgan Distribution Services, Inc., which is an affiliate of JPMorgan Chase & Co. Affiliates of JPMorgan Chase & Co. receive fees for providing various services to the funds. Products and services are offered by JPMorgan Distribution Services, Inc., is a member of FINRA/SIPC. J.P. Morgan Asset Management is the marketing name for the asset management businesses of JPMorgan Chase & Co. Those businesses include, but are not limited to, JPMorgan Chase Bank N.A., J.P. Morgan Investment Management Inc., Security Capital Research & Management Incorporated and J.P. Morgan Alternative Asset Management, Inc. Copyright 2015 JPMorgan Chase & Co. July 2015 RI-CUSTOMTDF

12 NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE J.P. MORGAN ASSET MANAGEMENT 270 Park Avenue I New York, NY RI-CUSTOMTDF

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